background image
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 23

Other Income

(1) Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that Contracting State.

(2) The provision of paragraph \ shall not apply to income, other than income from immovable as defined in paragraph 2 of Article 7, if the recipient of such income, being a resident of a contracting state, carrying business in the other contracting state through a permanent establishment situated therein, or performs in that other state independent personal services from a fixed base situated therein, and the right property in respect of which is the income is paid is effectively connect with such permanent establishment or fixed base. Such case the provision of article 8 or article 15, as the case may be, shall apply.

(3) Notwithstanding the provision of paragraphs 1 and 2, items of income of a resident a contracting state not dealt with in the foregoing articles of this agreement and arising in the other contracting state may also be taxed in that other state.